Aznar V Yapdiangco Case Study

registration, the principal, who is the true owner of the motor vehicle, is precluded from denying the agent’s authority to sell. The true owner who did not take back the actual possession of the motor vehicle is, by his conduct, precluded from denying the authority to sell.[ NCC, Article 1505.]
3. Distinction between Voluntary Delivery and Involuntary Delivery of the Motor Vehicle to the Seller

A distinction between voluntary delivery and involuntary delivery of the motor vehicle is essential to further clarify the context of unlawful deprivation in this thesis. The case of Aznar v. Yapdiangco[ G.R. No. L-18536, March 31, 1965] elucidates a case wherein the delivery of the movable property is involuntary, and is therefore considered as stolen
When the seller’s son reached the house of the buyer, the latter told the former that his payment lacked Php 2,000.00 and begged the former that he be allowed to get the balance from his sister. The buyer suggested that the seller’s son accompany his nephew to pick up the money. He also asked for the registration papers and deed of sale for the reason that he would show them to his lawyer. The seller’s son and the buyer’s nephew together with an unidentified companion proceeded to the home of the buyer’s sister, where the seller’s son was made to wait in their living room. After a long period of waiting, the seller’s son decided to go outside where discovered that the motor vehicle and the unidentified companion were no longer there. He entered the home again searching for the buyer’s nephew. The woman he talked to informed him that no person by that name was known in the residence. He rushed back to where the buyer was left and found a closed house and the buyer was no longer there. He proceeded to his father who in turn reported the incident to the police. The Court ruled that the buyer in this case never acquired title to the motor vehicle because even if the deed of sale was executed, the car was never delivered to the buyer. Article 559 was applied to this case. Thus, the delivery in this case was considered involuntary because the seller never had the intention of delivering the motor vehicle until payment was
The Common Law Principle of Equity

Article 559 of the Civil Code runs counter to an established common law principle of equity because it gives protection to an owner of a motor vehicle who has acted without prudence by making possible the transfer of its ownership to an individual who subsequently becomes a seller of the same property purchased by a buyer in good faith and for value. The latter loses his right to the ownership and possession of the motor vehicle despite the consummation of a valid sale. This part of the paper discusses the application of the common law principle to the proposal of the author.

It is an established principle of equity that: “Between two innocent parties, the one whose acts made possible the injury must shoulder the consequences thereof”.[ Tagactac v. Jimenez, G.R. no. 13514-R, February 22, 1957.] This means that if the true and registered owner of a motor vehicle entrusts or allows another individual to possess the motor vehicle and its certificate of registration and official receipt, he is in effect giving such individual an opportunity to transfer the registration of the motor vehicle in his name and thereafter to sell the motor vehicle to a third person acting as a buyer in good faith and for